1. What is the Grifols Ethics Line?
The Grifols Ethics Line is a comprehensive and confidential phone and internet-based reporting system to assist Grifols team members and external parties to raise concerns, issues or questions in relation to misconduct over corporate policies or applicable laws, and rules and regulations.
2. Who operates Grifols Ethics Line?
The Grifols Ethics Line is operated by NAVEX, an independent company. NAVEX’s independence from Grifols provides employees an added level of comfort and security that their reports remain confidential.
3. Why do we have Grifols Ethics Line?
An effective reporting system supports our efforts to foster a culture of trust, integrity and ethical decision-making. Although we always encourage open communication with direct managers, compliance, legal advisors, or internal audit, by providing this channel of communication, we ensure there is always a comfortable venue for employees and external parties to seek help or raise concerns.
4. When should I use Grifols Ethics Line?
If you witness any behavior at work which you feel may be a breach of our Code of Conduct or seems illegal or unethical, please report it. You must report any behavior which you suspect to be unlawful or criminal. This could be bribery, fraud, price fixing or a breach of data privacy. You must also report abuse of our systems, processes or policies. This could be bullying or harassment, a conflict of interest, danger to the health and safety of employees or the public, potential abuses of human rights or serious environmental issues. Grifols has a non-retaliation policy for when a genuine concern has been reported. No action will be taken against you if you report such concerns, even if there is no proven unlawful conduct of compliance breach.
5. What happens when I raise a concern?
If you give your name, the assigned Grifols investigator may contact you through email or phone to ask for more information. You may make a report anonymously. However, Grifols is better able to protect you from retaliation and to investigate your report if you provide your name. NAVEX and Grifols will treat your identity in confidence and it will only be disclosed, if necessary, to investigators or in subsequent legal proceedings, where allowed by local law.
All investigations are assigned to personnel who are appropriately trained and independent of the area in which the concern arose, ensuring impartiality and confidentiality of the investigations.
Any report you make will be kept confidential to the fullest extent possible consistent with the law and good business practices.
6. Can I get in trouble for using Grifols Ethics Line?
Protecting the identity of people who raise a concern in good faith is our priority. Grifols will not tolerate retaliation against an employee who raises a genuine concern. We will keep what you tell us private and confidential throughout the investigation process, subject to our legal obligations. Anonymous reporting is also available and included as an option when reporting through Grifols Ethics Line. Note: Anonymous reports may limit our ability to conduct an investigation.
7. How do I use the Grifols Ethics Line?
Grifols Ethics Line has two methods of intake. The first is by toll free telephone number, which is available to you 24/7 throughout the entire year. When you call, a professionally trained intake specialist will guide you through a series of questions designed to identify the relevant details of your concern.
We encourage you to give your name and contact information and the intake specialist will note that information. If you choose to remain anonymous, we will make no effort to trace the call or take steps to learn your identity. If you choose to identify yourself, Grifols will make every reasonable effort to hold your name in confidence during the investigation or follow up.
At the conclusion of the call, the intake specialist will summarize the information you have submitted and make any changes necessary to make sure that you are satisfied with the accuracy of your concern. Multilingual operators are available so that callers can raise concerns in their own language.
The second option is to use the web intake portal system. You may access it from any computer or mobile device with an internet connection. Your experience is nearly the same as reporting a concern by phone, except that you are simply providing the information by typing into the form versus providing it live to a person on the phone. The form is submitted directly to the third party, NAVEX, just as the information provided over the phone call.
8. What if I remember something important about the incident after I complete the form?
When you file a report via the Grifols Ethics Line, either over the internet or by telephone, you receive a unique report key and are asked to select a password. With the Report Key and your Password, you can return to the system again, either by internet or telephone, and access the original report through the “Follow Up” section on the home page. At that point, you can add more details.
9. What should I do if I lose my report key or password?
In order to maintain the highest level of confidentiality, you will be asked to file a new concern if you lose either your Report Key or your Password. You should mention in the new report that the matter relates to another report you filed earlier.
10. Is the Grifols Ethics Line secure?
Yes, your concern is stored directly onto the NAVEX secure server to prevent any possible security breach. Reported concerns are only made available to the Ombudsperson, Internal Audit, Legal, Compliance or HR (only for human resources matters) team members who are charged with investigating the reports based on the type of reported concern and location of the incident. Each of these team members, including extended team members such as subject matter experts, has had training in keeping these reports confidential to the fullest extent possible.
11. Should I identify myself or remain anonymous?
If you choose to identify yourself in raising your concern, the company will make every reasonable effort to keep your name confidential during the investigation. Investigations can be quicker and effectively completed when the reporter is identified because it allows company investigators to follow up directly with the reporter. If you choose to remain anonymous, no effort will be made by either NAVEX or Grifols to identify you.
12. If I remain anonymous, how can investigators contact me for follow up?
Once you have finished reporting your concern, you will be provided with a Report Key and asked to create a Password. With these two pieces of identification, you will be able to follow up either by telephone or through the web. If an investigator wishes to contact you regarding your concern, the investigator can leave you a message or ask you a question through the Grifols Ethics Line platform.
13. How will I receive information on the status of my case?
You will be given a report key and password. Make sure you record these and keep them in a safe place. You may use your report key and password to re-connect to check on the status of your case, provide more information, or answer follow-up questions from those who are investigating the matter. You may need to wait a few days after your submission to monitor progress and see if any additional information is required.
14. What if my line manager or the management are involved in a concern? won’t they get the report and change behaviour?
The Grifols Ethics Line system and report distribution protocols are designed so implicated parties are not notified about or granted access to reports in which they have been named, unless required by local laws.
15. I am a contractor working on a Grifols contract and I have a concern to report. Can I use the Grifols Ethics Line?
Yes. The Grifols Ethics Line is for the use of employees and external stakeholders, such as contractors, suppliers, business partners, joint venture partners, customers and agents of Grifols.